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FS 170-15
2603.3
Proponent: Samir Mokashi (samir.mokashi@codeul.com); Avery Lindeman, Green Science Policy Institute,
representing Green Science Policy Institute (avery@greensciencepolicy.org); Veena Singla, Natural Resources
Defense Council, representing Natural Resources Defense Council (vsingla@nrdc.org); Bruce Hammond,
Hammond & Company Inc., representing Hammond & Company, Inc. (bruce@hammondandcompany.com);
Tom Lent, Healthy Building Network, representing Healthy Building Network (tlent@healthybuilding.net); Nancy
Hulsey, HKS, Inc. , representing HKS, Inc. (nhulsey@hksinc.com); Joshua Klyber (JoshuaKlyber@gmail.com);
Vytenis Babrauskas, Fire Science & Technology Inc., representing Fire Science & Technology Inc.; Robin
Guenther, representing Perkins+Will (robin.guenther@perkinswill.com); David Eisenberg, Development Center
for Appropriate Technology, representing Development Center for Appropriate Technology
(strawnet@gmail.com); Marjorie Smith, Siegel & Strain Architects, representing Siegel & Strain Architects
(Msmith@siegelstrain.com); Stacia Miller, International Living Future Institute, representing International Living
Future Institute (stacia.miller@living-future.org); Clark Brockman, SERA Architects, Inc., representing SERA
Architects, Inc. (clarkb@serapdx.com); Larry Strain, representing Siegel & Strain Architects
(lstrain@siegelstrain.com); Russ Pitkin, SERA Architects, Inc., representing SERA Architects, Inc; Kathy
Gerwig, Kaiser Permanente (kathy.gerwig@kp.org); Tony Stefani, representing San Francisco Firefighters
Cancer Prevention Foundation; Dennis Murphy, USGBC California, representing USGBC California
(dennis@usgbc-california.org); Martin Hammer, representing Martin Hammer, Architect
(mfhammer@pacbell.net)
2015 International Building Code
Revise as follows:
2603.3 Surface-burning characteristics. Unless otherwise indicated in this section, foam plastic insulation and foam plastic
cores of manufactured assemblies shall have a flame spread index of not more than 75 and a smoke-developed index of not
more than 450 where tested in the maximum thickness intended for use in accordance with ASTM E 84 or UL 723. Loose filltype foam plastic insulation shall be tested as board stock for the flame spread and smoke-developed indexes.
Exceptions:
1. Smoke-developed index for interior trim as provided for in Section 2604.2.
2. In cold storage buildings, ice plants, food plants, food processing rooms and similar areas, foam plastic
insulation where tested in a thickness of 4 inches (102 mm) shall be permitted in a thickness up to 10
inches (254 mm) where the building is equipped throughout with an automatic fire sprinkler system in
accordance with Section 903.3.1.1. The approved automatic sprinkler system shall be provided in both the
room and that part of the building in which the room is located.
3. Foam plastic insulation that is a part of a Class A, B or C roof-covering assembly provided the assembly
with the foam plastic insulation satisfactorily passes NFPA 276 or UL 1256. The smoke-developed index
shall not be limited for roof applications.
4. Foam plastic insulation greater than 4 inches (102 mm) in thickness shall have a maximum flame spread
index of 75 and a smoke-developed index of 450 where tested at a minimum thickness of 4 inches (102
mm), provided the end use is approved in accordance with Section 2603.9 using the thickness and density
intended for use.
5. Flame spread and smoke-developed indexes for foam plastic interior signs in covered and open mall
buildings provided the signs comply with Section 402.6.4.
6. Foam plastic insulation located between a concrete slab on grade and its subgrade. Such insulation shall
also be exempt from the limiting oxygen index (LOI) requirements of ASTM C578.
Reason: This proposal exempts foam plastic insulation used between a concrete slab on grade and its subgrade from the flame spread index (FSI)
and smoke-developed index (SDI) requirements of Section 2603.3 and from the limiting oxygen index (LOI) criteria of ASTM C578. This will maintain
building fire safety while reducing the health and environmental impacts of toxic or potentially toxic flame retardant chemicals, and it will increase
consumer choice.
Ignition and propagation of fire requires three elements: fuel, an ignition source, and oxygen. The proposed exemption from FSI, SDI, and LOI
requirements applies only to foam plastic insulation protected between a concrete slab on grade and its subgrade, where there is no significant
exposure to ignition sources or oxygen. Since the foam plastic insulation will not burn under these conditions, the provisions of Section 2603.3, which
limit the surface burning characteristics (FSI and SDI) of foam plastic insulation, are not relevant and provide no fire safety benefit. Similarly, there is no
fire safety benefit from meeting the limiting oxygen index (LOI) criteria in ASTM C578. FSI, SDI, and LOI requirements are unnecessary for belowgrade uses of foam plastic insulation, where the elements required for a fire do not exist. However, the flame retardants used in foam plastic insulation
to meet these requirements pose a significant hazard to human health and ecosystems.
ICC COMMITTEE ACTION HEARINGS ::: April, 2015
FS258
The proposed change does not require additional protection at slab joints or penetrations beyond those required by other applicable code provisions.
At these locations it is highly unlikely that foam plastic insulation will be exposed to an ignition source, and if a portion of the insulation were somehow
exposed, there would not be sufficient oxygen to propagate fire. Other slab-on-grade insulation that is not substantially covered by the slab, such as
insulation between a slab edge and a foundation wall, is not covered by the proposed exception, and must comply with Section 2603.3 as well as
Section 2603.4 (thermal barriers).
Satisfying the FSI, SDI, and LOI criteria typically requires the addition of flame retardants to foam plastic insulation. During manufacture and installation,
workers are likely to be exposed to these flame retardants, which have been associated with neurological and reproductive impairments, hormonal and
immune problems, and cancer. These flame retardants are released into the environment during manufacture, demolition, and disposal, and they will
eventually migrate out of landfills and other repositories. When thermally processed or burned (for instance, in an incinerator or a landfill), insulation
containing halogenated flame retardants can generate highly persistent and toxic halogenated dioxins and furans and other toxic combustion
byproducts. Exposure to these dioxins and furans has been associated with cancer and other human health and ecological harm.
HBCD (hexabromocyclododecane) is the flame retardant used most commonly in polystyrene insulation, a typical variety of foam plastic insulation
used below-grade. In 2013 under the Stockholm Convention, over 150 countries agreed to eliminate HBCD from the global marketplace due to its
persistence and toxicity. The chemical alternatives to HBCD are also highly persistent halogenated flame retardants and are expected to have some
comparable adverse human health and ecological impacts. Reducing the unnecessary use of harmful flame retardants will reduce exposure and harm
to construction workers, emergency responders, the general public, and ecosystems.
The proposed change does not prohibit the use of flame retardants in foam plastic insulation. Instead, it describes conditions under which foam plastic
insulation without added flame retardants can be used safely in buildings.
It is envisioned that insulation without flame retardants for use as described in this proposed exception would require labeling that complies with Section
2603.2. This labeling would be the responsibility of the insulation manufacturer, in the same way that it is currently the manufacturer's responsibility to
properly label foam plastic insulation for the end uses described in Exceptions 1 through 5 of Section 2603.3.
This code change will maintain fire safety, reduce the adverse health and environmental impacts of toxic flame retardants used in foam plastic
insulation, and expand consumer choice.
Cost Impact: Will not increase the cost of construction
The proposed code change will not require any action that increases construction costs since it does not mandate any change from current practice.
Utilizing the proposed code change would not require any alteration to design or construction practices. The proposed change would enable voluntary
manufacture and use of alternative foam plastic insulation products that do not contain flame retardant chemicals. The cost of using these alternative
insulation products may be higher, lower, or the same as the cost of using currently available insulation depending on formulation costs, production
volumes, consumer demand, and level of competition.
FS 170-15 : 2603.3-LINDEMAN3804
ICC COMMITTEE ACTION HEARINGS ::: April, 2015
FS259